§ 101,[4] citing the In re Bilski [5] case, which disputed a method of hedging risk in the field of commodities trading.
The court also took into consideration three specific exceptions under 35 U.S.C section 101, which are "laws of nature", "physical phenomena", and "abstract ideas".
[1] First, the court argued that the Claim 3 did not pass the machine-or-transformation test because the internet cannot perform the fraud detection steps by itself.
Further, the court mentioned that the mere collection and organization of data regarding credit card numbers and Internet addresses is insufficient to meet the transformation prong of the test.
Second, the court examined the claim outside the scope of the machine-or-transformation test like in the Bilski v. Kappos case.
Because no algorithms of any kind and each of the steps in Claim 3 are conceivably doable in the human mind, they are represented by "basic tools of scientific and technological work".
[9] This case has shed light on patent-eligibility specifically related to the broad treatment of the internet as a machine.